California, United States of America
The following excerpt is from People v. Motuga, G046239 (Cal. App. 2013):
Defendant next asserts the cumulative effect of the court's errors and the prosecutor's misconduct resulted in an unfair trial. But only one instance of misconduct arguably occurred, and therefore no prejudice could accumulate. (See People v. Phillips (2000) 22 Cal.4th 226, 244.)
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